So you want to store medical records with third party providers or "in the
cloud"?  Well, provisions in HIPAA may be "here to help"... and they're
contained in the new Omnibus Rule. 

http://goo.gl/C1ob3

"The rules are set to change further and failure to comply can result in
compliance reviews, investigations, seven figure financial penalties, and
other sanctions."

So sharpen your pencils, write (or re-write) those Business Associates
Agreements to clearly state who is responsible for what, and then see who is
willing to provide services for you.  KEEP IN MIND, just because you have a
BAA with YOUR 3rd party provider, that doesn't mean when they farm your
information out to someone else that you're STILL protected!!

Larry
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